Privacy Policy

Introduction

Recomm (“Recomm,” “we,” or “us”) is committed to protecting and respecting your privacy.This Privacy Policy (together with our Terms of Use: Terms of use ​and any other documents referred to in them) applies to the Recomm mobile application (“Application”) and sets out the basis on which any personal data we collect from you, or thatyou provide to us, will be handled by us.

In this Privacy Policy, the term “personal data” means information that relates to an identified or identifiable natural person. “Sensitive personal data” means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, and the processing of data concerning health or sex life.

We know that you are concerned about how we use and disclose personal data, and we are committed to complying with data protection and privacy laws that apply to us.This Privacy Policy tells you about the ways in which we protect your privacy and the personal data we process about you.

We wish to remind you that this Privacy Policy applies to personal data that we process when you use the Application. It does not apply to any links to third-party websites, applications, or services that you may encounter when you use the Application. We encourage you to carefully familiarize yourself with privacy policies applicable to any websites or services operated by third parties. Please be aware that we are not responsible for the privacy practices of any third parties.

By using the Application, you agree to the privacy practices described in this Privacy Policy.

Information We May Collect from You

(i) Data You Provide in the Application

We may collect the following information from our users that may, in certain circumstances, constitute personal data:

●  User’s full name;

●  Profile photo;

●  Avatar;

●  Videos uploaded by users;

●  Billing name;

●  Billing address;

●  Email address;

●  Email password;

●  Mailing address;

●  Application password;

●  Third-party-service usernames and passwords used to sign in to the Application;

●  Any other information you provide to us;

●  Information we receive about you from third parties.

(ii) Data Collected Automatically

The Application may automatically collect the following information from you that in certain circumstances may constitute personal data:

● We and our third-party partners use cookies, web beacons, Flash cookies (locally stored objects), embedded scripts, location-identifying technologies, and similar technology (collectively, “tracking technologies”). These tracking technologies collect information about how you use the Application (e.g. actions you take in the Application), information about your browser and online usage patterns (e.g. IP address, browser type, browser language), and information about the devices you use to access the Application (e.g. device type, model and manufacturer, device operating system brand and model, device hard disk drive, operating system version, information regarding the location of your device), or we may be able to approximate a device’s location by analyzing other information, like an IP address. We may also collect the configuration of the Application when you use it and the time and date of your use of theApplication.
●  We also collect analytics data and use third-party analytics tools to help us measure traffic and usage trends for theApplication.

The Purposes for Which We Use the Data

We use the collected personal data for the following purposes:

●  To verify your identity;

●  To determine your eligibility to use the Application;

● To communicate with you, including for marketing purposes;

●  To prevent and investigate fraud, unauthorized use, and other misuses;

●  To operate and improve our products and services;

●  To audit and analyze the Application; and

●  To ensure the technical functionality and security of the Application.

We use the data collected automatically for the following purposes:

●  To improve customer service;

●  To personalize user experience;

●  To provide features available in the Application;

●  To develop, improve, and protect the Application;

●  For market research;

●  To audit and analyze the Application;

●  To ensure the technical functionality and security of the Application;

● To remember information so that you will not have to reenter it during your visit or thenext time you visit the Application;

●  To provide custom, personalized content and information, including targeted contentand advertising;

●  To monitor aggregate metrics such as total number of visitors, traffic, usage, anddemographic patterns in our Application;

●  To provide for the security of the Application; and

●  To differentiate between the devices you use to access the Application in order toprevent desynchronization of the user database.

How We Disclose Data

We do not sell, lease, rent, or otherwise disclose the personal data relating to our users to third parties unless otherwise stated below.

The personal data collected in the Application may be disclosed in the following manner:

(i) Personal data you provide in the Application:

We may disclose personal data you provide to the Application with the following categories of third parties:

●  To public authorities, such as law enforcement, if we are legally required to do so or if we need to protect our rights or the rights of third parties;

●  To our subsidiaries and affiliates; or a subsequent owner, co-owner or operator of the Application and their advisors in connection with a corporate merger, consolidation, restructuring, or the sale of substantially all of our stock or assets or other corporate reorganization, in accordance with this Privacy Policy;

● To other third parties, if we determine that such disclosure should be made for reasons of national security, law enforcement, or other issues of public importance;

●  To advertisers, but we do not share information that personally identifies you (information such as your name or email address that by itself can be used to contact you or identifies who you are) unless you give us permission. For example, we may provide general demographic and interest information to advertisers (for example, that an ad was seen by a woman between the ages of 25 and 34 who lives in Madrid and likes software engineering) to help them better understand their audience. We also confirm which ads you were shown in the Application led you to make a purchase or take an action with an advertiser.

●  To other third parties, if we secure your prior consent to such disclosure.

(ii) Data collected automatically:

The data collected automatically in the Application may be disclosed to the following categories of third parties:

●  To public authorities, such as law enforcement, if we are legally required to do so or if we need to protect our rights or the rights of third parties; and

●  To our subsidiaries and affiliates; or a subsequent owner, co-owner or operator of theApplication and their advisors in connection with a corporate merger, consolidation, restructuring, or the sale of substantially all of our stock or assets or other corporate reorganization, in accordance with this PrivacyPolicy.

Moreover, we may disclose information to third parties in an aggregate format that does not constitute personal data and does not allow the identification of individual users.

Your Rights

You have the following rights with respect to the personal data we hold about you:

●  The right to know what data we hold about you: If you would like to know what personal data we hold about you, please contact us at support@recomm.com. We seek to promptly respond to your inquiry.

●  The right to have incomplete, incorrect, outdated, or unnecessary personal data corrected, deleted, or updated.The easiest way to correct, delete, or update the personal data you have provided to the Application is to log into the Application and enter the necessary changes in the account settings of the Application. If you have additional questions regarding the correction, deletion, or updating of the personal data we hold about you, please contact us at support@recomm.com. Please note, however, that we may not be able to modify or delete information in all circumstances, including if we are required by federal or state law to keep certain information about you for a certain period.

● The right to opt out of receiving electronic direct marketing communications from us.All electronic direct marketing communications that you may receive from us, such as email messages and text messages, give you the option of not receiving such communications from us in the future. If you have any additional questions about electronic direct marketing received from us, please contact us at support@recomm.com.​

Customers from California

California law provides California customers with specific rights with regard to the collection, sale, and disclosure of their personal information. If you are a California resident, you have the following rights:

● The right to request that we delete any personal information about you which we have collected from you. Nevertheless, we will not be required to comply with your request to delete your personal information if it is necessary for us to maintain your personal information for the reasons provided under California Civil Code Section1798.105(d).

● The right to request that we disclose to you the following:

(1)  The categories of personal information we have collected about you;

(2)  The categories of sources from which your personal information is collected;

(3)  The business or commercia lpurpose for collecting or selling your personal information;

(4)  The categories of third parties with whom the business shares your personalinformation; and

(5) The specific pieces of personal information we have collected about you.

● The right not to be discriminated against because you have exercised any of your rights under the CCPA.

We do not sell your personal information or collect data to facilitate or enable third parties to advertise to you.

Data Security

The security of personal data is important to us. For example, your user account is protected by a password, and the servers we use are secured and protected by a firewall. In addition, encrypted browsing is the default browsing mode in the Application. Even so, we can not guarantee that your personal data are always secure because data security measures in use from time to time may be vulnerable. Consequently, please be mindful of the risks that personal data about you may be exposed to when you use the Application.

We also periodically review and adjust security safeguards as the threat landscape evolves.Ultimately no security system is impenetrable, and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, our policy is to take reasonable steps to investigate the situation and, where appropriate, communicate with affected individuals.

International Transfers of Personal Data

Information collected through our website may be stored and processed in the United States or any other country in which we or our affiliates or service providers maintain facilities. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S.or any other country in which we or our affiliates or service providers maintain facilities and to the use and disclosure of information about you as described in this Privacy Policy.

Children’s Privacy

You must be at least eighteen (18) years of age to register with and use the Application. This Application is not directed to children under 13. We do not intend to collect personal data from children under 13.

Changes to the Privacy Policy

From time to time we may change this Privacy Policy. You can tell when changes have been made to the Privacy Policy by referring to the “Last Updated” legend at the top of this page. If we materially change the ways in which we use and disclose personal data, we will post a notice in the Application and send an email to our registered users.Your continued use of the Application following any changes to this Privacy Policy constitutes your acceptance of any such changes made.

Questions or Concerns?

Should you have any questions regarding this Privacy Policy, your privacy as it relates to the use of the Application, or the protection of the personal data we hold about you, please contact us via email at support@recomm.com​ or by mail at  info@recomm.com, Attention: Privacy. We seek to promptly resolve any concerns you may have.